Tax Reassessment Quashed: Revenue's Limitation Period Extension Rejected, Procedural Defects Invalidate Assessment Order

ITAT adjudicated a tax assessment reopening dispute, holding that revenue's attempt to extend limitation period through reminder communications was invalid. The tribunal rejected revenue's contention regarding 14-day response timeline, finding it inconsistent with judicial precedent. The assessment order was quashed as the section 148A(d) order and section 148 notice were issued beyond the prescribed limitation period. The tribunal determined that without a valid notice, the assessment order dated 30.05.2023 could not be sustained. The decision was rendered in favor of the assessee, effectively nullifying the tax department's reassessment proceedings due to procedural non-compliance with statutory timelines. .....

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